President Trump Issues Executive Order Expanding North Korea Sanctions

President Trump issued a new executive order (the EO) on September 21st that greatly expands the U.S. sanctions against North Korea, particularly secondary sanctions. Secondary sanctions apply to non-U.S. individuals and corporations and are imposed by the U.S. Secretary of the Treasury, in consultation with the U.S. Secretary of State. The EO establishes the following:

Broad new criteria for designating non-U.S. persons for sanctions, including blocking their assets in the United States

A “180 Day Rule” under which vessels and aircraft are barred from entering the U.S. for a period of 180 days after any port call or landing in North Korea

Authority for the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) to block any funds transiting accounts linked to North Korea that come within the U.S. or possession of a U.S. Person

Authority for OFAC to impose sanctions on foreign financial institutions that knowingly conducted or facilitated, on or after the date of the EO: (i) any significant transaction on behalf of certain blocked persons; or (ii) any significant transaction in connection with trade with North Korea